- The BEGES makes the carbon footprint mandatory from 500 employees (250 overseas), published on the ADEME platform.
- It covers scopes 1 and 2; scope 3 is mandatory only for companies subject to CSRD.
- It is updated every 4 years (private sector) and comes with a transition plan.
- Penalties: a fine up to €50,000 (€100,000 for a repeat offense), and above all possible exclusion from public tenders.
Is a carbon footprint mandatory?
Yes, above a certain threshold. The BEGES is a legal obligation requiring organizations above that threshold to measure their greenhouse gas (GHG) emissions and publish the result. It is the regulatory version of the company carbon footprint. Below the threshold, the exercise remains voluntary, but it is increasingly expected by customers, buyers and lenders.
The obligation and its scope are set by article L229-25 of the French Environmental Code.
Who must comply with the BEGES?
The obligation applies to:
- companies with at least 500 employees in mainland France, or 250 in the overseas departments and regions;
- public-law legal entities with more than 250 staff (hospitals, public institutions);
- State services;
- local authorities with more than 50,000 inhabitants (regions, departments, municipalities, metropolitan authorities, agglomeration communities).
Headcount is calculated according to the rules of the French Labor Code. The full list of organizations covered is available on the regulatory fact sheet of the Portail RSE.
BEGES or Bilan Carbone: what is the difference?
This is a frequent confusion. The BEGES is a regulatory obligation: a result to produce and publish. The Bilan Carbone® method, maintained by ADEME and the Association pour la transition Bas Carbone, is one of the tools that lets you produce it, and by far the most widespread in France. But it is not the only path: other recognized methods also meet the obligation.
What must the BEGES contain?
The report always covers direct emissions, scope 1 (on-site combustion, company vehicles, refrigerant leaks), and indirect emissions from purchased energy, scope 2 (electricity, heat, steam). These two scopes, and scope 3, are defined in our article on scopes 1, 2 and 3. Scope 3, the rest of the value chain (purchases, transport, travel, end of life of sold products), is only mandatory for companies subject to CSRD, which must cover their significant indirect emissions. For other private-sector companies, scope 3 remains recommended but not required. These rules are set by article R229-47 of the French Environmental Code.
What must the transition plan contain?
The transition plan, attached to the report, under article R229-47, must at a minimum:
- describe the actions implemented since the previous report and the results obtained;
- present separately, for direct emissions and for indirect emissions, the actions and the resources planned until the next report;
- state the overall volume of emission reductions expected, for direct and indirect emissions.
In other words, a plan limited to intentions, with no concrete actions and no quantified reduction target, does not meet the requirement. You can find more on the transition plan in our dedicated article.
How often must the report be updated?
The BEGES and its transition plan are updated every four years for private-sector companies, and every three years for public-law legal entities.
Where do you publish your GHG report?
The report and the transition plan must be published on the ADEME Bilans GES platform, which is open to the public. That publication is what makes the obligation enforceable: a report produced but not published does not make you compliant.
What penalties apply?
The penalty regime is framed by article R229-50-1 of the French Environmental Code. An authorized officer records the breach, the regional prefect gives the company formal notice to remedy it within a set deadline, and if the obligation is still not met, the prefect can order payment of the fine provided for in article L229-25: up to €50,000, raised to €100,000 in the event of a repeat offense. The prefect can also make the penalty public.
But the most sensitive point is the business one: access to public procurement. Since the 2023 loi Industrie Verte, a public buyer can exclude from a tender a company subject to the BEGES obligation that has not produced one for the previous year. And the State goes further in its own purchasing: since its responsible procurement scheme of December 2025, providing the BEGES and the transition plan is a mandatory condition of performance in its contracts for companies with more than 500 employees, according to the French State Purchasing Directorate.
In practice, financial penalties remain rarely applied and compliance is low: a study by Audencia, TBS and Columbia University (June 2024, reported by AEF Info) shows that the BEGES remains very little used, particularly by unlisted companies, and analyses of the public data on the ADEME platform put the share of entities publishing on time at around 30%.
The data in your BEGES is also useful elsewhere. What a CDP questionnaire reuses from it, and what has to be added, is covered in our article on CDP, carbon footprint and BEGES.
How do you prepare?
A BEGES cannot be sorted out the day before the deadline. Data collection is the longest phase, often two to three months for a first full report, and scope 3 requires going to look for information at your suppliers. You can find the full approach in our article dedicated to calculating a carbon footprint.
This is where Ditto comes in. Beyond centralizing your GHG data into a single source, the platform brings your emissions data, your reduction actions and your transition plan onto the same roadmap, along with your other CSR and QHSE workstreams. You steer measurement and action in one place, and a dedicated coach teaches you the method so you can run it yourself in the next cycle. At the outset, a platform like Ditto helps, but a well-kept spreadsheet and a realistic calendar are enough to make a real starting point.
Review your carbon obligations
A Ditto expert checks with you whether the BEGES applies to you, what you must publish and by when.
Mandatory carbon footprint (BEGES): key takeaways
| Question | Answer |
|---|---|
| Who must comply | Companies ≥ 500 employees (250 overseas), public entities ≥ 250 staff, local authorities > 50,000 inhabitants |
| Content | Scopes 1 and 2 mandatory; scope 3 mandatory if subject to CSRD, otherwise recommended; plus a transition plan |
| Frequency | Every 4 years (private), every 3 years (public) |
| Publication | ADEME Bilans GES platform, public |
| Penalty | Fine up to €50,000 (€100,000 for a repeat offense); above all, possible exclusion from public tenders |
| Below 500 employees | No obligation; simplified version encouraged (voluntary) for 50 to 500 employees |
Frequently asked questions
Does an SME with fewer than 500 employees have to produce a carbon footprint?
No, there is no legal BEGES obligation below 500 employees (250 overseas). ADEME offers and encourages a simplified version of the report for companies with 50 to 500 employees, but on a voluntary basis, not as an obligation. Below that threshold, the exercise remains a choice, and one increasingly expected by customers and lenders.
Is scope 3 mandatory in the BEGES?
It depends on your situation. Companies subject to CSRD must cover their significant indirect emissions, scope 3 included. Other private-sector companies are only required, on the indirect side, to report emissions related to energy (scope 2); scope 3 remains recommended but not required (article R229-47). It should not be neglected for all that: scope 3 usually represents most of the emissions, and it is the heaviest part to measure because it depends on your suppliers.
Is the BEGES enough to meet CSRD requirements?
No. The BEGES and CSRD are two distinct obligations. The emissions inventory is a reusable basis for CSRD climate reporting (standard ESRS E1), but CSRD goes further. You can find the link between the two in our article on carbon footprint and CSRD.
How long does it take to produce a BEGES?
Expect several months, with data collection the longest step, often two to three months according to ADEME for a first full report. Anticipating the deadline avoids a rushed report.
